Mickey Haller 4 - The Fifth Witness

she was engaged in a foreclosure fight with the bank and had a history of protesting outside the bank until our lawyers got a temporary restraining order keeping her away. It was her actions that were perceived as a threat and it looks like we were right about that.”
    I jumped up and objected, asking the judge to strike the end of Modesto’s answer as being inflammatory and prejudicial. The judge agreed and admonished Modesto to keep such opinions to himself.
    “Do you know, Mr. Modesto,” Freeman said, “whether Lisa Trammel had made a direct threat against anyone at the bank, including Mitchell Bondurant?”
    Rule number one was to turn all weaknesses into advantages. Freeman was asking my questions now, robbing me of the chance to inflect them with my own outrage.
    “No, not specifically. But it was our feeling in terms of threat assessment that she was someone we should keep an eye out for.”
    “Thank you, Mr. Modesto. Who did you give this file to within the LAPD?”
    “Detective Kurlen, who was heading up the investigation. I went directly to him with it.”
    “And did you have occasion to speak to Detective Kurlen again later in the day?”
    “Well, we spoke a few times as the investigation was progressing. He had questions about the surveillance cameras in the garage and other things.”
    “Was there a second time when you contacted him?”
    “Yes, when it came to my attention that one of our employees, a teller, had reported to her supervisor that she believed she had seen Lisa Trammel either near or on the bank property that morning. I thought that was information the police needed to have so I called Detective Kurlen and set up an interview for him with the teller.”
    “And was that Margo Schafer?”
    “Yes, it was.”
    Freeman ended her direct examination there and turned the witness over to me. I decided it would be best to get in and out, sow a few seeds and come back to harvest later.
    “Mr. Modesto, as chief of corporate security at WestLand, did you have access to the foreclosure action the bank was taking against Lisa Trammel?”
    Modesto emphatically shook his head.
    “No, that was a legal case and as such I was not privy to it.”
    “So when you gave Detective Kurlen that file with Lisa Trammel’s name at the top of the list, you wouldn’t have known if she was about to lose her house or not, correct?”
    “That is correct.”
    “You wouldn’t have known if the bank was in the process of backing off her foreclosure because it had employed a company engaged in fraudulent activities, am I—”
    “Objection!” Freeman shrieked. “Assumes facts not in evidence.”
    “Sustained,” Perry said. “Mr. Haller, be careful here.”
    “Yes, Your Honor. Mr. Modesto, at the time you gave the threat file to Detective Kurlen, did you mention Lisa Trammel specifically or did you just hand him the file and let him go through it on his own?”
    “I told him she was on the top of our list.”
    “Did he ask you why?”
    “I don’t really recall. I just remember telling him about her but I can’t say for sure whether that was volunteered by me or whether he asked me specifically.”
    “And at the time you spoke to Detective Kurlen about Lisa Trammel as being a threat, you had no idea what the status of her foreclosure case was, correct?”
    “Yes, that is correct.”
    “So Detective Kurlen didn’t have that information either, am I right?”
    “I can’t speak for Detective Kurlen. You would have to ask him.”
    “Don’t worry, I will. I have no further questions at this time.”
    I checked the back wall as I returned to my seat. It was five minutes before five and I knew we were finished for the day. There was always so much that went into prepping for a trial. The end of the first day usually was accompanied by a wave of fatigue. I was just feeling it start to hit me.
    The judge admonished the jurors to keep an open mind about what they had heard and seen during the day. He told them to avoid media reports on the trial and not to discuss the case among themselves or with others. He then sent them home.
    My client went off with Herb Dahl, who had returned to the courthouse, and I followed Freeman through the gate.
    “Nice start,” I said to her.
    “Not bad yourself.”
    “Well, we both know you get to pick off the low-hanging fruit at the beginning of a trial. Then it’s gone and it gets tough.”
    “Yes, it’s going to get tough. Good luck, Haller.”
    Once in the